The principles of OMB UG  govern costs that may be charged either directly or indirectly to the government by Institutes of Higher Education (IHE’s).

The Uniform Administrative Requirements describe the costs that are eligible for reimbursement under federal grants and contracts (allowable costs), and the costs that are not eligible for reimbursement (unallowable costs). Refer to the Cost Principles in Subpart E, §200.400-200.475 of the Uniform Guidance for the full listing of types of costs. 

In general, there are three categories of expenses:

• Direct Expenses – These expenses can normally be directly charged to federal awards. However, the terms and conditions of the sponsored award must be reviewed prior to determining the appropriateness of expenses for each individual project.
• Indirect Expenses- Sometimes referred to as facilities and administrative (F&A) costs or overhead, these expenses may not be charged as direct expenses to federal awards unless the costs meet the “unlike purpose and circumstances criteria” further defined in this document.
• Unallowable expenses- These costs may not be charged to a federal award either as a direct charge or indirectly as recovered through the F&A rate. 

In addition to following grant-specific guidelines, recipients of grant funding are also expected to comply with established University policies and procedures. 

Subpart E of the Uniform Guidance – Cost Principles

Subpart E of the UG - Cost principles provides a detailed listing of items that are typically allowable and unallowable. Examples of costs normally considered unallowable include:

• Advertising and public relations
• Alcoholic beverages
• Bad Debt
• Convocations or other events related to instruction
• Entertainment
• Fines and penalties
• Fully depreciated assets
• Housing and personal living expenses
• Legal cost
• Lobbying
• Royalties or patents

Direct Costs are those costs that directly benefit a specific sponsored project. These are costs that can be identified specifically with a particular project, an instructional activity or any other institutional activity. They can be directly assigned to such activities relatively easily with a high degree of accuracy. 

 According to 2 § CFR 200.68 - Modified Total Direct Costs (MTDC) means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each sub-award (regardless of the period of performance of the sub-awards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each sub-award in excess of $25,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs, and with the approval of the cognizant agency for indirect costs. 

 According to 2 § CFR 200.56 Indirect Costs also known as F&A Costs ( Facilities and Administrative) means those costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect (F&A) costs. Indirect (F&A) cost pools should be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived.

They key to ensuring financial compliance is to understand and follow 2CFR 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award) 2 CFR 200 and any other sponsor or University regulations.  When managing sponsored funds on a daily basis ask the appropriate questions to ensure costs are reasonable, allocable and consistently treated.

If you still have further questions please consult with your SPAC team Analyst.

In the new Quantum system, award numbers are generated sequentially and cannot be modified to accommodate our previous procedure of using a suffix for continuations (Used in PeopleSoft).  We are only able to modify project numbers. The project numbering logic is that a project number is an extension of the award number with the last number being the current funding year for this award’s funding period. 

For new awards generated in Quantum:

Award number 2003746

Year 1 PID: 20037461

Year 1 Child PID: 20037461C1 – 1^st year funding, 1^st child

Year 1 Supplement PID: 20037461S1 – 1^st year supplement funding 

For old awards transferred over to Quantum:

Utilizing that logic for the old Award Numbers:  Award # 990873D

Yr. 1 PID:  10019983 (transferred from PeopleSoft)

Yr. 2 PID:  10021940 (transferred from PeopleSoft)

If we are funded for year 3 of the award utilizing the new logic:

Yr. 3 PID:  990873D3 (award number – year 3 funded)

For further information see Award/Budget Setup.

When an award and/or contract has been signed by both the sponsor and Sponsored Programs Administration (SPA), it is ready to receive an award number.  SPA will route a copy of the agreement/contract to Sponsored Projects Accounting and Compliance (SPAC) and SPAC will enter the budget, invoicing and financial reporting information into the university’s accounting system and will generate an account number for the award. 

It usually takes 2-3 business days for an account number to be generated after an award has been signed.  SPAC Analyst will then notify the department via email through their distribution list.

Committed Cost Share is usually indicated in Kuali Research on the proposal submitted to Sponsored Programs Administration (SPA).  Once the award and/or contract has been executed, and the information is routed to Sponsored Projects Accounting and Compliance (SPAC), SPAC enters the information in the award setup.

Departments can then see if cost share has been set up on a project by viewing the award in Quantum Financials under the Award Module; searching for the award then viewing under Projects (2) train-stop the Funding Source.

 In order to view you must have “UMB Grants Viewer” access.  Please contact your administrator for access.

New awards will be created based on the following:

1. Change in a Purchase Order (PO) Number
1. Single – usually Veterans Administration (VA)
2. Multiple PO’s on one award – usually from Baltimore County Public Schools (BCPS)
2. Change in Sponsor Contract Number (not adding the year at the end, the core # must change)
3. Change in Letter of Credit (LOC) ID
4. Change in Sponsor funding source (like LOC ID change – but this is a new funding window)

Transferring a faculty member to a new organization is a team effort between SPA and SPAC.  Both teams must be notified via the Departing PI Award Disposition Notification form.  

SPAC’s responsibility is to provide a financial summary of the expenditures on the PI’s list of awards.  SPAC will work with the department to provide an estimated relinquishing amount for the current period to the sponsor.  Once accepted by the sponsor, UMB has between 30-90 days to submit a final financial report which is a collaborative effort between the department and SPAC, with SPAC signing off on the final expenditure amount.

Awards that will be transferred within the University, the SPAC team along with the department will determine the final balance and then proceed to transfer that balance to the next PI or department.

For most Streamlined Non-Competing Award Process (SNAP) awards under NIH; funds are automatically carried over. For other Federal agencies carryover may not be automatic.  Therefore the PI has to make a request to the sponsor through SPA.  Once the approval is granted; the department can then request the carryover of funds using The Request and Approval for Carryover of Unobligated Balance - Carryover Allocation Form.

SPAC teams are divided into five (5) main areas:

• The Setup Team
• The Billing Teams (FED,  NonFed & VMS)
• The FFR Reporting Team (aka the Quality Assurance or “QA” Team)
• The Collections & Accounts Receivable (“CAR”) Team
• The Cost Analysis and Compliance Team

See here for information related to the different individuals that make up each team along with each area’s listing of responsibilities.

The Office of Sponsored Programs Administration (SPA) is authorized to sign proposals, awards and other non- financial official documents related to sponsored projects.  Principal Investigators should not sign any documents as the authorized University signatory.  The Office of Sponsored Projects Accounting and Compliance (SPAC) signs invoices, financial statements and other documents related to financial activities on sponsored projects.

SPAC’s Financial Analyst in collaboration with the department will prepare financial reports required by the Sponsor.  The department is required to verify and provide documentation when necessary to support the expenditures. 

The SPAC manager will review for accuracy and compliance and will submit to the sponsoring agency.

This depends on the sponsor and the type of agreement.  Most Federal agencies, such as NIH, pay via letter of credit (LOC) draw downs. Funds are drawn bi-weekly and monthly from the sponsor. These funds match-up to prior month’s expenditures, as long as the expenditures are within the budget.    

 For non- Federal awards the sponsors pay based on Costs Basis (billable on actual expenses in the financial system), pre-determined Scheduled Basis and Volume basis for Deliverables.  Invoices are usually generated on a monthly basis, but may differ depending on the terms of the contract.

SPAC in collaboration with the department and the PI are responsible for the collection of AR balances. The PI must ensure timely submission of progress reports and SPAC must provide timely billing support. 

When payments are past due at 31-60 days the department is contacted to help facilitate collections.  Ultimately the department is responsible for any receivables which cannot be collected from the sponsor.

Checks sent directly to the department should be deposited at the Cashier’s Office. For procedures and required forms to document transaction please refer to the following link. https://www.umaryland.edu/student-financial-services/university-cashier/

The information will be under Departmental Deposits.

FAQs from COFAR on the New Uniform Guidance

Check, ACH Payments and Invoice Copies